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, I
June 3, 2016
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49
Subject: FLEX Strategies Phase 2 Staffing Assessment
References:
NEXTeraM· ENERGY~
NG-16-0120
DUANE ARNOLD
1. NRG Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012(ML12054A736)
2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities (ML 12125A412)
On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued an order (Reference 1) to all power reactor licensees, including NextEra Energy Duane Arnold, LLC's, (hereafter, NextEra Energy Duane Arnold). Reference 1 was immediately effective and directs NextEra Energy Duane Arnold to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyonddesign-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1. Reference 2 is industry guidance document NEI 12-01 for determining the response of on-shift and augmented resources to an Extended Loss of Power (ELAP).
Please find as Enclosure 1 to this letter, a copy of NextEra Energy Duane Arnold's Phase 2 Staffing Assessment Report for a Beyond Design Basis External Event (BDBEE) for NextEra Energy Duane Arnold per NEI 12-01.
The assessment was conducted using Emergency Operating Procedures (EOPs) and Severe Accident Management Procedures (SAMPs).
This letter contains no new commitments nor does it revise any existing commitments.
NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324
Document Control Desk NG-16-0120 Page 2 of 2
Should you have any questions regarding this matter, please contact Mike Davis, Licensing Manager at (319) 851-7032.
Sincerely,
~~~~ T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC
Enclosure
cc: Regional Administrator, USNRC, Region Ill Resident Inspector, USNRC, Duane Arnold Energy Center Project Manager, USNRC, Duane Arnold Energy Center
Duane Arnold Energy Center
FLEX Strategies Phase 2 Staffing Assessment
38 Pages to follow
Enclosure 1 to NG-16-0120
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Review and Approval
Prepared by Paul Brozenich Signature on file Date -------
Reviewed by Tim Holt Signature on file Date -------
Reviewed by Mark Fritz Signature on file Date -------
Reviewed by Tom Rohe Signature on file Date -------
Approved by Ron Lingle Signature on file Date ------
1
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Table of Contents
Executive Summary •.•..••••.•..•••.•.•.••.•••.•...•.••••...•..••.•.•.•.•••••••...••.•.••..•••.•...•..•••• 3
Introduction ...•......••.....................••.•.•............•.............••.•...............•.........•.•• 5
Staffing Assessment Process Overview •.••.••.•....•...••••••••.•.••..•...•.••.•.•....••••••.•••• 6
NEI 12-01 Phas·e 2 Assessment Results .•.••••••••.•..••.•.•.•..•.•..••••••••.••.•....•••.....••. 7.
Phase 2 Staffing Assessment Details •••••••••.•.••.••...•.•.•••••••••.••••...••••••.•.•••.•••••••• 8
Assumptions •.......•••.•..•.••.•........•.•............................••••.•.........•...........•......... 9
Methodology .•••.•.••••..•.•.•.•.••••.••.•••••••••••.•.•.••....•.•.••.•.•.••.••••••.••••.•.•.••....•..•••• 13
Security Considerations .•.•••••.••.••.•.••••••••....•.•.•••..••.•.•..•.•.•••••••••.•..•.•.••••.•.•...• 16
Strategy Resource Loading ....•.•.•.•••••••.•.•.•.•..•.••.••••.•.•. : .••.••••••....•.•.•.•••••.•..••• 21
Appendix 1 Staffing Tables ••.•...•••••••.•.•.•.•.••.•.••••••.•.•..•.•••••••...•.••...•••••..•.•..•.. 24
2
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Executive Summary
This report documents the results of an assessment of the capability of the Duane Arnold
Energy Center (DAEC) minimum on-shift staff and augmented Emergency Response
Organization (ERO) to respond to a beyond design basis external event (BDBEE). The
assumptions for the scenario are based on accepted industry guidance and postulate that the
BDBEE involves a large-scale external natural event that results in:
A. An extended loss of AC power (HAP)
B. An extended loss of the ultimate heat sink (LUHS)
C. Unit in operation at the time of the event
D. Impeded access to the unit by off-site responders as follows:
• · Oto 6 hours post event - No site access. (Initial Phase)
• 6 to 24 hours post event - Limited site access. Individuals may access the site by
walking, personal vehicle or via alternate tran-sportation capabilities (e.g., private
resource providers or public sector support). (Transition Phase)
• 24+ hours post event - Improved site access. Site access is restored to a near
normal status and/or augmented transportation resources are available to
deliver equipment, supplies, and large numbers of personnel. (Final Phase)
The assessment of the minimum on-shift staffing was performed by a team of DAEC subject
matter experts from Operations, Radiation Protection, Security, Emergency Preparedness, and
the FLEX project team. The team performed the staffing assessment on March 23-24 2016.
The participants reviewed the assumptions and applied existing procedural guidance, including
applicable draft Severe Accident Management Procedures (SAMPs) for coping with a BDBEE
using minimu·m on-shift staffing. Particular attention was given to the sequence and timing of
each procedural step, its duration, and the on-shift individual performing the step to account
for both the task and the time duration analyses of NEI 10-05, Assessment of On-Shift
Emergency Response Organization and Capabilities.
The on-shift staffing analysis concluded that there were no task overlaps for the activities that
were assigned to the on-shift personnel. However, SAMP task training was not complete at the
time of this assessment. Training will be delivered to E-plan on-shift staff and applicable
qualifications applied and maintained to implement the FLEX strategies. These training
3
FUKUSHTh1A RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
activities are tracked by AR 1744135-24. No additional shift staffing is necessary to implement
the mitigating strategies for DAEC. The evaluation utilized the minimum E-plan .on-shift staff
from Operations, Radiation Protection, Chemistry, Fire Brig~de and Security to accomplish all
applicable event response tasks.
4
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Introduction
This report documents a preliminary staffing assessment for a Beyond Design Basis External
Event for Duane Arnold Energy Center. The assessmen·t was performed using guidance in NEI
12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and
Communication Capabilities," and NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide," to determine the response of on-shift and augmented resources to an
Extended Loss of Power (ELAP). The assessment addresses Phase 1 and 2 of the analysis
applicable to implementation of existing and preliminary FLEX strategies for prolonged loss of
offsite power initial and transition phases of the event, utilizing the methodology of NEI 10-05,
"Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." The
procedures, at the time of the assessment, were in a draft development state. When the
procedures are finalized, a review will be conducted to ensure inputs to this staffing analysis
remain valid.
The assessment was conducted using draft Severe Accident Management Procedures (SAMPs)
and Emergency Operating Procedure (EOP) revisions. Use of these procedures is acceptable in
accordance with NEI 12-01:
"In accordance with the Order, each licensee must develop new strategies for mitigating
the effects of beyond-design-basis external events. To ensure accurate results, the
staffing assessment for response functions related to NTTF Recommendation 4.2 must
be based on actions delineated in the procedures and guidelines developed in response
to the Order. Once the site-specific actions associated with the new response strategies
are defined (e.g., down to the procedure or guideline step level), the staffing needed to
perform these actions can be assessed with the necessary level of accuracy."
The assessment considers required actions performed during the Initial and Transition Phases
of an ELAP (first 24 hours). Evaluation of the first 24 hours of response is acceptable in
accordance with NEI 12-01, Section 3.1 and NEI 12-06, Section 12.1:
"Following successful implementation of Transition Phase coping strategies, there is a
, third phase characterized by the ability to cope indefinitely; this is referred to as the
Final Phase (Phase 3). The Final Phase would involve the use of equipment and
consumables transported to the site from offsite locations, including ongoing
replacement and replenishment as needed. The demands placed upon the ERO during
this phase are not significantly different than those associated with Transition Phase
coping."
5
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
"On-site resources will be used to cope with the first two phases of the casualty for a minimum
of the first 24 hours of the event."
Staffing Assessment Process Overview
Draft strategies for responding to an ELAP and draft Severe Accident Management Procedures
(SAMPs) were evaluated during the NEI 12-01 Phase 2 Staffing Assessment by a multi
disciplined team .. The staffing assessment also addressed the ability of the on-shift staff to
perform any required emergency response functions prior to the delayed arrival of the
augmented Emergency Response Organization (ERO).
· The Phase 2 staffing assessment requires that the ELAP scenario be evaluated based on the
minimum staffing in the Emergency Plan (NEI 12-01) and the supplemental staff allowed by the
minimum administrative staffing procedures (NEI 12-06). DAEC Radiological Emergency Plan
Table B-1, Revision 37 documents the approved minimum Emergency Plan on-shift staff. Table
1 below summarizes the available personnel.
Table 1-DAEC on - Shift Staffing
Line On-Shift Position Generic On-Title Shift
1. Operations Shift Manager (OSM) SRO 1
2. Control Room Supervisor (CRS) SRO 1
3 Shift Technical Advisor (STA) SRO 1 4. Nuclear Station Operating Engineer (NSOE) RO 1
5. Assistant Nuclear Station Operating Engineer(ANSOE) RO (FBL) 1
6. Extra Assistant Nuclear Station Operating Engineer (EANSOE) RO 1 7. Second Assistant Nuclear Station Operating Engineer
(SANSOE) AO 1
8. Nuclear Station Auxiliaries Operator (NSAO) AO 1
9. Nuclear Station Plant Equipment Operator (NSPEO) AO Radwaste Operator (FBM) 1
10. Health Physics Technician #1 RP 1
11. Health Physics Technician #2 RP 1
12. Chemistry Technician CT 1 13. Shift Communicator SC 1
14. Security watchman (FBM) FBM 1 15. Maintenance #1 FBM 1
16. Maintenance #2 FBM 1
Security Sec plan
SRO- Senior Reactor Operator, RO-Reactor Operator, AO- Auxiliary Operator, FBL-Fire Brigade
Leader, FBM-Fire Brigade Member, SC-Shift Communicator
6
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
The DAEC FIRE PROTECTION PROGRAM FP-AB-100 identifies Fire Brigade staffing as being
composed of the Assistant Nuclear Station Operating Engineer (RO) as the Fire Brigade Leader,
Maintenance (2), Security, (1) and the Radwaste operator (1).
NEI 12-01 Phase 2 Assessment Results
No conflicts or overlaps in functions or tasks required to be performed by on-shift operations
and support personnel were identified during this analysis. Transition Phase actions were
requir~d within the first six hours of the event.
Using NEI 12-01 and NEI 12-06 guidance, the minimum on-shift staff (as defined in the DAEC
Emergency Plan B "Emerg~ncy Response Organization" Rev 37, Table B-1) performed all actions
required by operating and emergency plan procedures in the first phase relying only on
installed structures, systems and components in the initial phase of the response. After the
ELAP condition was declared, functional draft Severe Accident Management Procedures
(S~MPs) and applicable attachments were successfully implemented. They were performed
using on-shift resources during the first six (6) hours and augmented responders from six (6) to
twenty-four {24) hours as necessary for relief.
DAEC's phase 2 FLEX response relies upon the use of portable equipment. An evaluation of the
SAMPs was conducted for the scenario. Validation & Verification (V & V} of the FLEX portable
equipment deployment was conducted prior to the table top evaluation. The V & V was
completed to determine the resources needed and estimated durations of each task associated
with the strategy. The staffing assessment used the total number of resources identified and
task durations to ensure DAEC can respond to an ELAP. The primary response to an ELAP event
at DAEC is with installed equipment in phase one and portable equipment in phase 2.
A review of draft SAMPs was conducted to determine the resources needed and estimated
durations of each task associated with the strategy. The total number of resources identified
and task duration were then used to identify the two most resource limiting FLEX strategies.
This analysis identified that the two most resource limiting FLEX strategies are:
• SAMP 724, FLEX Damage Assessment and Portable Equipment Deployment
• SAMP 722, FLEX Repowering Battery Chargers from FLEX 480 VAC DG
There were no required staffing or Emergency Plan changes identified during this assessment.
7
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Phase 2 Staffing Assessment Details
The Phase 2 staffing assessment for DAEC was conducted on March 24 and 25, 2016 with a
Simulator Validation Scenario on March 25, 2016, using the guidance of NEI 12-01, NEI 12-06
and NEI 10-05.
The following personnel were present to complete the assessment:
Table 2 - Staffing Analysis Team
Personnel (Position/Title) Number Organization,/Department
Senior Reactor Operator (SRO} 1
Reactor Operator (RO} 1 Operations
Health Physics Foreman 1 Radiation Protection
EP Coordinator 1 Emergency Preparedness
EP Manager 1
FLEX Program Owner 1 Program Engineering
Security Shift Supervisor 1 Security
Fukushima Project Personnel 3 Fukushima Project
Simulator Scenario Personnel
SRO 1 Operations
RO 2
Operations Instructor 1 Operations Training
Fukushima Project Personnel 5 Fukushima Project
8
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Ass·umptions
The extended loss of AC power event was evaluated using the following assumptions,
consistent with NEI 12-01, NEI 12-06 and applicable assumptions from NEI 10-05.
NEI 12-01-Assumptions for Staffing Assessment:
1. A large-scale external event occurs that results in:
• extended loss of AC power
• impeded access to the unit
2. Initially, the reactor is operating at full power and is successfully shut down.
3. A Hostile Action directed at the affected site does not occur during the period that
the site is responding to the event.
4. The event impedes site access as follows:
a. Post-event time: 6 hours - No site access. This duration reflects the time
necessary to clear roadway obstructions, use different travel routes, mobilize
alternate transportation capabilities (e.g., private resource providers or
public sector support), etc.
b. Post-event time: 6 to 24 hours - Limited site access. Individuals may access
the site by walking, personal vehicle or via alternate transportation
capabilities (e.g., private resource providers or public sector support).
c. Rost-event time: 24+ hours - Improved site access. Site access is restored to
a near-normal status and/or augmented transportation resources are
. available to deliver equipment, supplies and large numbers of personnel.
5. On-shift personnel are limited to the minimum complement allowed by the site
emergency plan and Fire Protection Program.
9
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
NEI 10-05 - Applicable Assumptions:
1. On-shift personnel can report to their assigned response locations within
· timeframes sufficient to allow for performance of assigned actions,
2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain
normal dosimetry to enter Radiological Controlled Areas (but not locked high or very
high radiation areas) without the aid of a Radiation Protection Technician .
. 3. Personnel assigned to the major response area of Plant Operations & Safe Shutdown
meet the requirements and guidance established by NRC regulations and are able to
satisfactorily perform the functions and tasks necessary to achieve and maintain safe
shutdown. Staff performance within this area is not evaluated as part of this
assessment, unless a role/function/task from another major response_ area is
assigned as a collateral duty.
4. On-site security organization: Performance of this function is regularly analyzed
through other station programs and will not be evaluated here, unless a role or
function from another major response area is assigned as a collateral duty.
5. Individuals holding the position of radiation Protection technician or chemistry
technician are qualified to perform the range of tasks expected of their position.
6. The task of making a simple and brief communication has minimal impact on the
ability to perform other assigned functions/tasks, and is therefore an acceptable
collateral duty for all positions. This assumption does not apply to emergency
notification to an Offsite Response Organization (ORO) or the NRC. These actions
must be assessed.
7. The task of performing a peer check has minimal impact on the ability to perform
other assigned functions/tasks, and is therefore an acceptable collateral duty for all
positions.
8. The analyzed events occur during off-normal work hours at a time when most
augmented ERO responders are not at the site (e.g., during a backshift, weekend or
holiday). For purposes of this analysis, and consistent with NEI 12-01 assumption #4,
360 minutes (6 hours) will be used as the time period for the conduct of on-shift ERO
response actions.
10
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
NEI 12-06 Assumptions
1. Prior to the event the reactor has been operating at 100 percent rated thermal
power for at least 100 days or has just been shut down from such a power history as
required by plant procedures in advance of the impending event.
2. At the time ofthe postulated event, the reactor and supporting systems are within
normal operating ranges for pressure, temperature, and water level for the
appropriate plant condition. All plant equipment is either normally operating or
available from the standby state as described in the plant design and licensing basis.
3. No specific initiating event is used. The initial condition is assumed to be a loss of
off-site power (LOOP) at the plant site resulting from an external event that affects
the off-site power system either throughout the grid or at the plant with no prospect
for recovery of off-site power for an extended period.
4. All installed sources of emergency on-site AC power and SBO Alternate ac power
sources are assumed to be not available and not imminently recoverable.
5. Cooling and makeup water inventories contained in systems or structures with
designs that are robust with respect to for the applicable hazard(s) are available
6. Normal access to the ultimate heat sink is lost, but the water inventory in the UHS
remains available and robust piping connecting the UHS to plant systems remains
intact. The motive force for UHS flow, i.e., pumps, is assumed to be lost with no
prospect for recovery.
7. Fuel for FLEX equipment stored in structures with designs which are robust for the
applicable hazard (s) remains available.
8. Permanent plant equipment that is contained in structures with designs that are
robust for the applicable hazard(s) is available.
9. Other equipment, such as portable AC power sources, portable back up DC power
supplies: spare batteries, and LOLA equipment, may be used as on-site FLEX
equipment provided it is reasonably protected from the applicable external hazards
per NEI 12-06 Sections 5 through 9 and Section 11.3, and has predetermined hookup
strategies with appropriate procedures/guidance and the equipment is stqred in a
relative close vicinity of the site.
10.. Installed electrical distribution system, including inverters and battery chargers,
remain available provided they are protected consistent with current station design.
11
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
11. No additional events or failures are assumed to occur immediately prior to or during
the event, including security events.
12. The fire protection system ring header as a water source is acceptable only if the
header is robust for the applicable hazard(s).
Plant Specific Assumptions .
1. Plant Instrument Air is not assumed to be available during the assessment period.
2. RCS Inventory:
'-a) ·, Reactor Coolant inventory losses are limited to nornial system leakage
(identified and unidentified), recirculation pump seal leakage of 18 gpm per
seal at Operating pressure, and losses due to HPCI, RCIC and SRV operation.
3. Station batteries Following Station Blackout Procedure AOP 301.1 load shed will
provide power for the listed durations: ·
a) lDl Division 1, 125VDC station battery will continue to provide power for at
least 8 hours following load shed
b) 1D2 Division 2, 125VDC battery will continue to provide power for at least 10
hours following load shed.
c) 1D4 250VDC station battery will continue to provide power for at least 10
hours following load shed.
4. Plant communications will be available as follows:
a) The plant public address system is available in the reactor building and control
building for 4 hours.
b) A total of 24 hand held radios with a capacity of 8-12 hours under anticipated
load, are stored in the control building and are. functional.
c) Portable Satellite phones are functional in the control room, TSC, EOF, OSC.
d) A portable 120VAC generator supplies power for charging portable
communications radios and satellite phone batteries.
5. The Suppression Pool is initially the source of makeup water to the Reactor.
12
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
a) A portable diesel pump supplies water from the Circulating water pit to the
Reactor following transition from RCIC. Circulating water pit inventory is
sufficient for core cooling until Phase 3.
6. Station Batteries and inverters supply plant instrumentation.
7. Spent Fuel Pool Makeup or Spray equipment staging actions are desired before
impediments to access could occur.
8. An Alternative Security Approach is implemented at DAEC to aid response to the
beyond-design-basis external event.
9. All equipment:credited in current coping strategies remains available for use.
10. During the ELAP, plant-personnel are allowed to enter the Radiological Controlled
Area without processing through the Radiological Protection control point.
11. The Emergency Off-Site Facility is located approximately 15 miles from the site and
is available as a staging facility. The EOF is provided with a backup diesel generator.
METHODOLOGY
An assessment of on-shift staffing was performed using NEI 12-01, NEI 12-06 and NEI 10-05
guidance. Subject matter_ experts were assembled to provide analysis support. The
assessment was conducted via a tabletop procedural analysis using DAEC procedures to
determine iftasks have been sufficiently analyzed for performance by the minimum on-shift
staff as designated in the Emergency Plan as allowed by NEI 12-06. The following provides a
summary of the process that was used.
Each on-shift position from Emergency Plan Section 'B' Emergency Response Organization
TABLE B-1 and any additional administrative on-shift position were entered in NEI 10-05
Appendix 1, Table 1. For position titles with more than one position holder, a unique
sequential number was assigned to each position. The site emergency plan reference that
· describes the requirement for the position to be on-shift was then entered into column 3 of
Appendix 1, NEI 10-05 Table 1. Firefighting was not applicable for this assessment. Using
only the on-shift positions entered in the table, the following Appendix 1 tables were
completed by entering the shift position that fills a described role, or performs a specific
function or tasks:
• NEI 10-05 Table 2 - Minimum Operations Crew Necessary to Implement AOPs and
EOPs, SAMPs or SAMGs if applicable.
13
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
• Table 2B - Procedural Implementation Time line of activities corresponding to Table
2
• NEI 10-05 Table 3-Fire Fighting (not applicable for this event analysis)
• NEI 10-05 Table 4-:Radiation Protection & Chemistry Time Line of Activities
• NEI 10-05 Table 5-Emergency Plan Implementation
• Table 5A-E-Plan Implementation Time Line
Following completion of each of the above tables, each on-shift position assigned to the
associated table was lo.cated on Appendix 1, NEI 10-05 Table 1. For _each position, the table
number and associated line number was then entered in column 4, "Role in Table#/Line#".
If the associated task required additional actions, a "Yes" was placed in the last column and
the additional action recorded in the results section ofthis report.
The On-Shift Staffing Assessment (OSA) was conducted using the following process:
1. Selection of_ the multi-disciplined work group
2. Scheduling the tabletop at the DAEC Operations support Center (OSC) to allow ready
access to required procedures and administrative documents
3. Conduct of a pre-jolJ briefing outlining the requirements of NEI 12-01, NEI 12-06 and
NEI 10-05
4. Review of the event initial conditions and assumptions·
5. Performance of the tablet~p procedural analysis
6. Documentation of the results of the tabletop by Fukushima project group using the
NEI 10-05 forms modified to extend to 24 hours.
This review provided the team with a basic understanding of the event and resulting emergency
classifications. The SRO reviewed EOP, AOP and SAMP actions and identified them to the team.
The procedures for FLEX strategies are in draft status which is adequate for a staffing
assessment. When the procedures are finalized a review of the staffing assessment will be
performed to ensure that the staffing assessment results have not changed. This activity is
tracked by AR 2126130.
Resources needed to perform the initial and transition phase response actions were identified
from the EOP, AOP, or SAMP procedures and documented. The team determined when other
on-shift resources, such as the RP or Chemistry Technician, would be required and identified
14
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
the time required to perform expected emergency plan functions. This information was
documented on the applicable tables in this report. Finally, the on-shift resources and their
actions were summarized in the tables using the NEI 10-05 documentation process in Appendix
1, NEI 10-05 Table 1. One scenario, ELAP with loss of Ultimate Heat Sink was reviewed.
15
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Security Considerations
Existing emergency procedures do not require the use of Security Officers to perform duties
unrelated to their assigned roles. However, planned mitigation strategies require Members of
the Security Force (MSF) to perform duties unrelated to their assigned roles, (e.g., debris
removal and equipment staging).
Security Officers will perform functions within their current roles such as monitoring, damage
assessment and controlling sites access and providing compensating measures for any vital area
doors that may need to remain open to facilitate room environmental conditions and hose and
personnel passage.
To the extent practical; security posture and security functions will be relaxed to facilitate
immediate onsite and offsite response to the emergency. No additional events or failures are
assumed to occur prior to or during a BDBEE including security events.
In preparation for response to an ELAP and a LUHS an alternative security_approach has been
developed. This alternative approach will enable event mitigation, while ensuring a level of
protection appropriate for the circumstance. This approach is a site specific plan which includes
elements such as establishing unassisted access for event mitigation and providing security
personnel to assist with event mitigation. The site security department will be trained and
prepared to implement the alternative approach when properly authorized. This training
activity is tracked by AR 1744135-24.
Security personnel shall be the last group requested for assistance and the first group relieved
once additional emergency response personnel arrive onsite. Security positions selected for
reassignment to FLEX response activities are tiered and sequenced and consider position
reassignment impacts to security responses under the protective strategy from the "least
impactful". This is in line with the NRC guidance for an ELAP event for reassigning Security
officers to FLEX response activities.
Site specific staffing assessments have estimated that 28 MSFs will be trained as FLEX Auxiliary
Responders and will be responsible for debris removal from travel paths, transporting onsite
portable equipment to staged locations, and assisting in deployment of hoses and cables. Of
the possible 5 shift responders, 2 will be assigned per shift as FLEX Auxiliary Responders, -
available as needed for postulated beyond design basis events.
16
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
DAEC responses to Staffing Assessment Questions Related to Use of Security Personnel during
a BOB Event Response
1. · How has the site evaluated the use of on-shift personnel (excluding security) to
address staffing and the movement of equipment for a beyond design basis event in
phases 1, 2, and 3 mitigating strategies?
DAEC Response:
The site has evaluated the use of on-shift personnel (excluding security) to address
staffing and the movement of equipment for a beyond design basis event in phases
1, 2, and 3 mitigating strategies in accordance with the NRC staff-endorsed guidance
contained in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident
Response Staffing and Communications Capabilities.
NOTE -The Mitigating Strategi~s Order and NRC JLD-ISG-2012-01 refers to' Phases 1,
2 and 3 as the Initial Phase, Transition Pbase and Final Phase, respectively.
2. All apparent immediate actions taken to address the condition without the use of
security (e.g., the exhaustive use of other site personnel).
a.) How is "immediately" defined for the use of security personnel to support
the site event?
DAEC Response:
Immediately is defined as the moment at which the senior license operator in
the Control Room determines that an event has occurred, or plant conditions
are present, which will require implementation of Severe Accident
Management procedures (e.g., deployment of Initial Phase and/or Transition
Phase Mitigating strategies).
17
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
b.) What are the other actions that may be taken before using 10 CFR 73.SS(p)?
DAEC Response:
Through implementation of the appropriate procedures and guidelines, Control
Room operators will select the appropriate mitigating strategies for responding to
the post-event plant conditions, and direct the performance of the in-field/plant
actions necessary to implement these strategies. Consistent with the goal of
protecting public health and safety, implementation of strategies will utilize the on
site staff in such a way as to ensure that equipment retrieval and operation occurs
within the timeframes necessary to maintain safety functions. ·
3. Is the site considering the use of security personnel for other beyond design basis
events that are not characterized by the conditions outlined within the guidance
document? If so what are these events and the associated rationale for using
security personnel?
DAEC Response:
No; the site is not considering the use of Security personnel for other beyor:id design
basis events that are not characterized by the conditions outlined within the
, guidance document.
4. Technical information concerning why the use of Security P.ersonnel would address
the condition.
DAEC response:
The use of security personnel would address the condition because of their
availability as a response resource to the Control Room and will help to ensure that
mitigating strategies are implemented within the timeframes necessary to maintain
safety functions. Such implementation will preclude or minimize offsite radiological
consequences, and thus contribute to the protection of public health and safety.
[NOTE: No additional events or failures are assumed to occur immediately prior to or
during the event including security events]
Security personnel will be supporting implementation of the following event
mitigation procedures and guidelines:
• SAMP 724- FLEX Damage Assessment and Portable Equipment
Deployment
18
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
5. If security is used to meet staffing requirements and the placement of equipment,
what phase(s) would require their support?
DAEC Response:
Security support would be necessary during Phase 1 and Phase 2 (Initial Phase and
Transition Phase).
6. The rationale concerning the use of security personnel:
a.) How many secu.rity personnel are necessary to support the event?
DAEC Response:
Two (2) security personnel are necessary to support the event.
b.) What security requirements in part or total are impacted by the use of the
security personnel?
DAEC Response: An Assessment Table below represents the response to 6b.
Non-Safeguards Staffing Assessment Table
Position Mitigating Strategy Duty
Operate pre-staged heavy equipment and
Auxiliary Responder #1 perform debris removal. 'May also include
assisting plant Operations with deployment of
FLEX equipment as necessary.
Operate pre-staged heavy equipment and
Auxiliary Responder #2 perform debris removal. May also include
assisting plant Operations with deployment of
FLEX equipment as necessary.
c.) What is the estimated duration for the use of security personnel?
DAEC Response:
Notwithstanding the uncertainties associated with a beyond design basis
event, the estimated duration is bounded as stated below.
19
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
• As noted earlier, the "start time" is the moment at which the senior
licensed operator in the Control Room determines that an event has
occurr~d or plant conditions are present, which will require
implementation of Severe Accident Management Procedures (e.g.,
deployment of Initial Phase and/or Transition Phase mitigating
strategies).
• With respect to the "end time", it is anticipated that augmented ERO
staff would be able to access the site at around 6 hours following the
event. Allowing for some margin in the arrival times of ERO
· personnel, the need to do job briefings and turnovers, the release of
security personnel from mitigating strategies duties should occur
. during the period of approximately 6 to 12 hours after the initiating
event.
d.) What are the duties that will be assigned to security personnel?
DAEC Response:
See response to question 6b, above. The staffing assessment has verified that
the designated security personnel do not have non-security related task
assignments that would prevent them from performing their mitigating
strategy implementation duties (i.e., no assigned collateral duties). Response
training for security personnel will be developed in accordance with the
guidance in NEI 12-06.
e.) What actions will be required to restore security to its normal posture?
DAEC Response:
The actions that will allow for dismissal of security personnel from duties
associated with implementation of mitigating strategies would be the arrival
of a sufficient number of augmented ERO personnel. Once dismissed,
security personnel may resume their normal duties.
Appropriate procedures and guidelines will contain instructions to the effect
that absent an overriding safety consideration, security personnel will
receive priority consideration for mitigating strategy duty relief by the
augmented ERO.
7. Is the use of security personnel conducted via a tiered approach to minimize impact
to security response capability? Use of security personnel should be sequenced such
20
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
that security personnel whose reassignment will adversely ·impact security the least
are reassigned first (e.g. use security personnel who are performing admini.strative
functions before those who are implementing the protective strategy).
DAEC Response:
Yes; the use of security personnel was determined via a tiered approach to minimize
the impact to security response capability. The selection of personnel considered
assigned functions and potential impacts to the protective strategy. The assignments
were .made such that security personnel with the least impact to the protective
str;;itegy were reassigned first. The assignment shown in the Table above (response
to question 6b) reflects the selection rationale; least to greater impact
Strategy Resource Loading
Selected SAMPs were reviewed to determine the resources needed and estimated durations of
each task associated with the FLEX strategy. The resources and time frames have been
incorporated into Table 2B for ELAP response.
21
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Strategy Resource Loading
SAMP Description Resources Notes
708 Emergency RPV makeup with Ops (1) PDFP & hose trailer . the Portable Diesel Fire Pump FBM (1) previously staged
during deployment 715 Portable Diesel Fire Pump FBM (2) ·Deploy PDFP & suction
Operation hose connect 721 FLEX 480 VAC Diesel FBM (1) Starting PDG
Generator Operation 722 FLEX Repowering Battery FBM (3) Cable run to Battery
Chargers from FLEX 480 VAC Chargers DG
723 Flex Repowering MCC 1 B32 FBM (2) or Cable run to 1 B32 and from A FLEX 480 VAC ERO (2) breaker lineup Portable Diesel generator
724 FLEX Damage Assessment FBM (5) Damage assessment and Portable Equipment and deployment route Deployment selection '
724 FLEX Damage Assessment FBM (5) Debris removal from and Portable Equipment deployment routes and Deployment equipment staging
areas 724 FLEX Damage Assessment FBM (2)· Deploy Cable trailer
and Portable Equipment Deployment
724 FLEX Damage Assessment_ FBM (2) Deploy PDFP & stage and Portable Equipment Deployment
724 FLEX Damage Assessment FBM (2) Deploy & stage Hose and Portable Equipment trailer Deployment
-22
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Strategy Resource Loading
SAMP Description Resources . Notes
708 Emergency RPV makeup with FBM (2) Connect 5" discharge the Portable Diesel Fire Pump hose to PDFP and run
hose to turbine building 724 FLEX Damage Assessment FBM (2) Deploy portable
. and Portable Equipment 480VAC DG Deployment
722 FLEX Repowering Battery FBM (1) Battery Charger Chargers from Flex 480 VAC breaker Lineup DG
725 FLEX Alternate Power to FBM (2) or Deploy 120 VAC PDG Instrument AC ERO (2) & cable connection
727 FLEX Local Instrument Obtain Instrument Rack Readings Ops (1), or readings and Fluke
ER0(1) measurements at Fo~boro panels
729 Flex Ventilation Of the Reactor Ops(1) or Opening of the refuel Building without AC Power FBM(1) floor Roof vent Damper
and Opening Rx Bldg. Airlock door
730 Flex Guidelines for RCIC use Ops(1) Operational Guideline during a BDBEE only
23
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1 - Staffing Tables
NEI 12-01 Phase 2 Analysis
On-Shift Personnel Assignments Used During Analysis
Operations On-Shift Assignments
Position Designation Assignment
Shift Manager SM (SRO) Shift Manager/Site Emergency Coordinator
Control Room Supervisor CRS (SRO) Control Room Command .and Control
Control Room Operator RO#l Control Room Operator
Control Room Operator R0#2 Control Room Operator
NSPEO AO#l Auxiliary Operator
NSPEO A0#2 Auxiliary Operator
Shift Technical Advisor STA Crew Oversight
Control Room Operator FBL(R0#3) Fire Brigade Leader
Radwaste Operator FBM#2 Fire brigade Member
Shift Communicator SC Communications EP communicator
Other On-Shift Assignments Used During Analysis
Position Designation - Assignment
RP Technician RP#l RP Support
RP Technician RP#2 RP Support
Maintenance #1 FBM#3 Fire Brigade member
Maintenance #2 FBM#4 Fire Brigade member
Chemistry Technician CT1 Chemistry Sampling/Dose Assessment
Security* FBM#S Fire Brigade Member
Security Supervisor and SEC* Security Supervision/Control & Command and personnel per the security duties as assigned by the control room to
plan include portable equipment staging support.
*Security personnel numbers are safeguards information. Personnel are per the security plan.
Security SME during the staffing assessment verified security personnel would be available to
perform the functions of controlling site access and compensatory measures for any doors or
gates that need to remain open for support of portable equipment mobilization.
24
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
Extended Loss of all AC Power (ELAP)
NEI 10-05 Table 1-DAEC on - shift Staffing
Line On-Shift Position Emergency Plan Role In Table#/ Action
Reference Line# Required
1. Shift Manager E Plan Table B-1 Table 2/Ll, Table Yes
5/L1,L2,L3,L5
2. Control Room Supervisor E Plan Table B-1 T2/L2 Yes
3. Reactor Operator #1 E Plan Table B-1 T2/L4 Yes
4. Reactor Operator #2 E Plan Table B-1 T2/L6 Yes
5. NSPEO #l(Auxiliary E Plan Table B-1 T2/L7 Yes
Operator)
6. NSPEO #2(Auxiliary E Plan Table B-1 T2/L8 Yes Operator)
7. Shift Technical Advisor E Plan Table B-1 T2/L3, T5/L9 Yes
8. Reactor Operator #3 FBL E Plan Table B-1/Fire T2/L5 Yes plan
9. Health Physics Technician E Plan Table B-1 T2/L11, T4/Ll No
RP#l
10. Health Physics Technician E Plan.Table B-1 T 2/L12, T 4/L2 No RP#2
11. Chemistry Technician CTl E Plan Table B-1 Table 2/L13, T4/L3 No
12. Radwaste Operator E Plan Table B-1/Fire Table 2/L9 Yes FBM#2 Plan
13. Security watchman E Plan Table B-1/Fire Table 2/LlO Yes
FBM#5 Plan
14. Shift Communicator E Plan Table B-1 Table 2/L16 No T5/L6,L7,L8,,L12
15. Maintenance #1 FBM#3 E Plan Table B-1/Fire Table 2/L14 · Yes Plan
16. Maintenance #2 FBM#4 E Plan Table B-1/F,ire Table 2/L15 Yes
Plan
17. Security (SEC) E Plan Table B-1 Table 5/L14 Yes
Notes: Note 1-Training required for assigned SAMP support actions (see Table 2A).
25
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
NEI 10-05 Table 2 - Plant Operations & Safe Shutdown
One Unit-One Control Room
Minimum Operations Crew Necessary to Implement
AOPs and EOPs, SAMPs or SAMGs if applicable
Line Generic Title/Role On Shift Position Task Performance Validation
1. Shift Manager Operations Shift Manager {OSM) Operator Training 2. Control Room Supervisor Control Room Supervisor {CRS) Operator Training 3. Shift Technical Advisor Shift Technical Advisor (STA) Operator Training
Nuclear Station Operating Engineer 4 Reactor Operator#l (NSOE) Operator Training
Assistant Nuclear Station Operating 5 Reactor Operator#3 Engineer(ANSOE) FBL Operator Training
Extra Assistant Nuclear Station Operating 6 Reactor Operator#2 Engineer (EANSOE) Operator Training
Second Assistant Nuclear Station 7 Auxiliary Operator #1 Operating Engineer (SANSOE) Operator Training
Nuclear Station Auxiliaries Operator 8 Auxiliary Operator #2 (NSAO) Operator Training
Nuclear Station Plant Equipment Operator 9 Radwaste Operator (FBM) Operator Training
Other (non-Operations) Personnel Necessary to Implement AOPs, EOPs, SAMPs, or SAMGs if applicable
Line Generic Title/Role On-Shift Position Task Performance
Validation
10 Security Officers Security Officers (SEC) Security Training Note 1
11 RP Technician RP Technician (RP1) RP Training Note 1
12 RP Technician RP Technician (RP2) RP Training Note 1
13 Chemistry Technician Chemistry Technician (CT1) Chemistry/EP Training Note 1
14 Maintenance# 1 Fire Brigade Fire Brigade Training
15 Maintenance # 2 Fire Brigade Fire Brigade Training
16 Shift Communicator Shift Communicator EP Training
Note 1: See Table 2A for FLEX training requirements;
See Table 2B for applicable AOP/EOP/SAMP actions.
26
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
TABLE 2A FLEX Training Requirements
TABLE 2A FLEX Training Requirements
Audience Lesson Training Setting an~ Approximate Duration
ERO Decision Makers Basic FLEX on NANTEL CBT 1 Hour and Evaluators Licensecl Operators Non-Licensed Operators Fire Brigade Security Personnel Maintenance General Plant Staff Licensed Operators Advanced FLEX on NANTEL CBT 1 Hour
Non-Licensed Operators Fire Brigade Security Personnel ERO Decision Makers and Evaluators Licensed Operators FLEX Site Specific Overview including CBT - 0.5 Hour Non-Licensed Operators OP-M-100-1005 Extreme Plant Fire Brigade Transient Response Rules Security Personnel ERO Decision Make.rs and Evaluators ERO Decision Makers HPCI I RHR logic Failures Class Room - 2.0 Hour and Evaluators Licensed Operators Licensed Operators RCIC Logic Failures Class Room -2.0 Hours ERO Decision Makers and Evaluators Licensed Operators Control of FLEX Equipment Out of Class Room -2.0 Hour
Service Times
Licensed operators AOP 301.1 Station Blackout , FLEX Class Room -2.0 Hours Non-licensed Operators Changes Simulator -2.0 Hours
SRO/STA FLEX Coping Strategies Overview Class Room - 2.0 Hours ERO Decision Makers and Evaluators -Licensed Operators . SAMP 724 Implementation Class Room - 2.0 Hours
27
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
TABLE 2A FLEX Training Requirements
Audience Lesson Training Setting and Approximate Duration
ERO Decision Makers Emergency Management Guidelines, Class Room -4.0 Hours and Evaluators Activate/coordinate with the NSRC, SRO/STA Overview SAMP 719,TSG update ERO Shift Communicator Licensed Operators AOP 435, Loss Of Fuel Pool Cooling or Class Room 1.0 Hour
Non-Licensed Operators Level, include SAMP 712, Spent Fuel Simulator 1.0 Hour Pool Makeup and Spray, SFPLI Mod traininQ
Licensed Operators EOP 3, Secondary Containment Control, Class Room - 1.0 Hour ERO Decision Makers FLEX Changes and Evaluators Licensed operators SAMP 727, FLEX Local Instrument Class Room - 4.0 Hours Non-Licensed operators Readings
SAMP 730, FLEX Guidelines for RCIC Use During a Beyond Design Basis External Event SAMP 729, FLEX Ventilation of the Reactor Building Without AC Power SAMP 731, FLEX Restoration of CV 4371A DW Valves N2 Supply Isolation (From 1T-128)
Security personnel Backhoe Qualification Class Room -8.0 Hours Practical -4 Hours
Licensed Operators SEP 301.3, Operation of Hard Pipe Vent Class Room - 1.0 Hour Non-Licensed operators DLA-1 Hour
Fire brigade SAMP 719, Emergency Refueling of Class room I Walk down -1 RO qualified ANSOE Diesel Powered Equipment 16 Hours 1 NSPEO Qualified RW 2 Security SAMP 721, FLEX 480VAC Diesel . 2 maintenance Generator Operation
SAMP 722, Repowering Battery Chargers from FLEX 480VAC DG
SAMP 723, Repowering MCC 1 B32 from 480VAC FLEX DG
SAMP 724, FLEX Damage Assessment and Portable Equipment Deployment
SAMP 725, FLEX Alternate Power to Instrument AC
28
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
TABLE 2A FLEX Training Requirements
Audience Lesson Training Setting and Approximate Duration
Fire Brigade SAMP 726, FLEX Adverse Combined with Fire Brigade Environmental Conditions training class room I walk
1 RO qualified ANSOE Guideline down on previous page
1 NSPEO Qualified RW SAMP 728, FLEX
2 Security Replenishment of Water Inventories
2 maintenance
29
FUKUSHIMA RESPONSE NEI 12-01PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
A end ix 1 Table 2B - Procedure Task Tim in , TSA-Time Sensitive Action
Step
Station Blackout EOP-1 RPV Control
EOP-1 RC/P
ACP 1410.1
EOP-1 AOP 301 .1 step 11
ACP1410.1
EPIP 1.1
EPIP 1.2 Notifications
EPIP 1.3
AOP 301.1step1a
AOP 301.1 step 2a
AOP 301 .1 step 2a
AOP 301 .1 step 2b
AOP 301 .1 step 2c/2d
AOP 301 .1 step 3
AOP 301.1 recheck
AOP 301.1 recheck
AOP 301 .1 recheck
AOP 301 .1 step 5
AOP 301 .1 step 7
AOP 301 .1 step 8
AOP 301 .1step10
AOP 301 .1 steps 10 a, b, c, d
AOP 301 .1step12
AOP 301.1step13
Procedure Step/Actions
Task
Event starts Stabilize RPV Level, Pressure, Verify RX shutdown, Verify Isolations & initiations Control RPV level with RCIC.
Override open CV 4371 A Defeat 11 . Place CV-4371 A Group 3 Override Switch in Override 0 en , Confirm CV-4371A 0 ens Parameter monitoring, Crew backup
RPV Cooldown with SRVs & RCIC <100F/Hr., to 150-200psig. Maintain RPV Pressure 150-200psig initiate cooldown log (attachment 7&8) Oversi ht
Determine EAL Site Area Erner enc (General Emergency)
Notify NRC
Accountability
Attachment 4 Open CR cabinet doors
Attachment 1 essential switch gear rooms ventilation .
Attachment 1 Security Support per Attachment 9 Doors
Attachment 5 Block open Control Room Doors
Issue Rx Bldg. Key Block Open HPCI Room upper and lower doors & notif Control Room
Critical parameter monitoring RPV Pressure, Torus Temperature, RPV cooldown
Declare ELAP TSA
Direct Fire Brigade to Implement SAMP 724 Damage Assessment & Portable Equipment De lo ment
Activate SAFER
implement Attachment 2 Main condenser and DG room instructions
Notify ITC Midwest of SBO
Place Bus transfer switches to manual
Implement Attachment 3 Essential switchgear Rooms instructions
Bypass RCIC and HPCI High Area Temperature Isolations
Perform Attachment 11 Secure MG set oil, Vent GEN H2
Periodically check Voltage at H and I breaker
Resource
Minimum shift crew CRS R01 R02 SM
STA
SM
SM
SC
SM
SM
SC
Minutes - Hour 1 0· 10-20 20· 30· 40-50 10 30 40
x
x
x
x
x
x
x
50-60
Minutes
120 180 240-300
Performance Time After Procedure Implementation
300-360
360-420
420-480
Hour
8 9 10 11
x
x
Intermittent Task for R01 and R02
12 13 14 15 16 17 18 19 20 21 22 23 24
30
A endix 1Table2B -Procedure Task Tim in , TSA-Time Sensitive Action
FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Procedure Step/Actions Performance Time After Procedure Implementation
Step
AOP 301.1step14
AOP 301 .1 step 15b
AOP 301 .1step19
SAMP 724 Section 1
SAMP 724 Section 1
SAMP 724
SAMP 724
SAMP 724 section 2.0
SAMP 7221 .0
SAMP 7221 .0
SAMP 722 Section 2.0
SAMP 724 Section 3.0,
SAMP 724 Section 3.0
SAMP 708 Section 1.0
SAMP 715 Section 1.1 Step 15
Task
Isolate Transformer deluge systems when Air Pressure is 50 #
Install Defeat 1 RCIC lo press isolation
Perform attachment 13 DC Load Shed Assess damage to ERBs and debris select deployment routes, start debris removal Security Support for Fencing removal , Gates, North & South T Bldg. Roll Up doors, Cable Trailer, PDFP and PDG Sta in
Debris Removal
Prepare for equipment deployment (manually open FLEX Building rollu doors
Deploy .Cable trailer to staging area
Security support for cable routing to 1A3 switch gear
SAMP 722 RP Support for Cable routing to 1A3 switch gear
Cable layout for 1D12
Return to ERB for PDFP deployment; Deploy PDFP.
Return to ERB for hose trailer; Deploy hose Trailer
Hose Layout Hose Trailer to South T Bldg. Roll up door
Open RHR Inject valve and hose layout RHR to south T Bldg. Roll up door
SAMP 722 Sections 3.0, 4.0 Cable Route to 10120 & 1D43
SAMP 708 Section
SAMP 7081 .0
SAMP 715 Section 1.0
SAMP 724 Section 2.0, SAMP 721 1.0, 2.0
SAMP 722 Section 2.0
SAMP 722 Sections 3.0 & 4.0 SAMP 708 SEP301 .3
SAMP 719
Start PDFP and pressurize hoses
Security support for PDFP Hose Routing South T building Roll up Door
Ready for Injection
Return to ERB for PDG ; Deploy, Stage, PDG
1D12 Battery supplied by PDG
1D120 & 1043 Batteries supplied by PDG
Depressurize RPV for PDFP injection
Vent Containment
Transport Refueling trailer, Refuel portable Equipment
Minutes - Hour 1
Resource 0- 10-20 20- 30- 40-50 10 30 40
FB#1 , FB#2,
FB#1 , FB#2
FB#1, FB#2
A01 , FB #5
50-60
Minutes
120 180 240-300
x
300-360
x
x
x
x
x
360-420
x
420-480
x
Hour
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
x
31
A end ix 1 Table 2B - Procedure Task Tim in , TSA-Time Sensitive Action
FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Procedure Step/Actions Performance Time After Procedure Implementation
Step
SAMP 712,Attachment 1, Ste 2 SAMP 712,Attachment 1, Ste 3 SAMP 712,Attachment 1, Ste 4
SAMP 712,Attachment 1, Step 5
SAMP 712 Attachment 1, Ste 6 SAMP 712 Attachment 1, Ste 7
Task
Route 5" Fire Hose To Power Block access point performed with SAMP 708 Section 1.0 Contact Security to Open Roll-up Doors and remove barriers to run fire hose into the ower block Performed Earlier
Connect 21/2" fire hose to wye adaptor
Route 21/2" Hoses through accessible doors and stairwells to SFP a. Secure hose along route b. Secure hose to direct makeup into SFP
Start PDFP & open discharge valve
Confirm hoses secure and water flow into pool
Minutes - Hour 1
Resource 0· 10-20 20· 30· 40-50 10 30 40
FB#1 , FB#2,
50-60
Minutes
120 180 240· 300
300-360
x
360-420
420-480
Hour
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
32
FUKUSHJMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
NEI 10-05 TABLE 3 - Firefighting
Line Performed By Task Analysis . Controlling Method
1. N/A N/A
2. N/A N/A
3. N/A N/A
4. N/A N/A
5. N/A N/A
Notes: Not required by scenario - Fire Brigade members available to support BDBEE response actions.
33
FUKUSHIMA RESPONSE NEJ 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
NEI 10-05 TABLE 4- Radiation Protection & Chemistry ELAP Response
Position Line Performing
Function/Task
1. Job Coverage On-Shift Position : RP1
2. Job Coverage On-Shift Position: RP2
3. Job Coverage On-Shift Position : CT1
Position Line Performing
Function/Task 1. Job Coverage
On-Shift Position: RP1
2. Job Coverage On-Shift Position: RP2
3. Job Coverage On-Shift Position: CT1
Performance Time Period After Event Initiation Minutes
0- 10- 20- 30- 40- 50-1 0 20 30 40 50 60
2 3
Hours
4 5 6 10
Job coverage and as neceStllllfY,;!ll'ji'J•• high radiation
Performance Time Period After Event Initiation (hours)
11 12 13 14 15 16 17 18 19 20 21 22 23 24
In Plant Surveys
34
FUKUSHIMA RESPONSE NEI 12-0 l PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
NEI 10-05 Table 5 - Emergency Plan Implementation
Line Function /Task
1. Declare the Emergency Classification Level
2. Approve Offsite protective Action Recommendations
3. Approve Content of State/Local notifications
4. Approve extension to allowable dose Limits
5. Notification and direction to on-shift staff {e .g. assemble, evacuate, etc.)
6. ERO notifications
7. Complete State/Local notification form
8. Perform State/Local notifications
9. Complete NRC Event notification form
10. Activate EROS
11. Offsite radiological assessment
12. Perform NRC notifications
13. Perform other Site specific notifications {e.g. INPO, SAFER, etc.)
14. Personnel Accountabi lity
ON-Shift Posit ion
SM
SM
SM
N/R SM SEC
SC
SC
SC
STA
N/A
N/R SC
SC
SEC
Notes: Note 1 - On-site Notifications to State/local agencies and NRC performed using battery
powered communications equipment installed in the Control Room.
Note 2 - EROS capability is unavailable due to BDBEE impact on communications infrastructure. Note 3 - Radiological release does not exist, offsite radiological assessment is not
required . Note 4- NRC Communications and other site-specific notifications assumed by EOF personnel once staffed and activated. N/R - Not Required N/ A - Not Applicable See Table SA for E-Plan implementation timeline
35
FUKUSHIMA RESPONSE NEI 12-0 1 PHASE 2 STAFFING ASSESSME T REPORT DUANE ARNOLD ENERGY CENTER
Appendix 1
Table SA - E-Plan Implementation Timeline
Function/Task
Declare the Emergency Approve Offsite PARs Approve State/Local Notification Form Approve extension to allowable dose limits Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.) ERO notification Complete State/local notification form
Perform State/local notifications ote
Complete NRC event notification form Activate EROS ote
Offsite radiolog ical assessment ote
Perform NRC notifications ote ·
Perform other site-specific event notifications (e.g. , INPO, ANI , etc.) Note
4
Personnel accountability
On-shift Position
SM SM SM N/R
SM
SC SC
SC STA N/A N/R SC N/A
SEC
3 6 9 12 15 18 21 24 27 30 35 x
x x
x
36
Table 5A Notes
FUKUSHlMA RESPONSE NEI 12-0 1PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER
Notes: Note 1 - On-site Notifications to State/local agencies and NRC performed using portable battery powered satellite communications equipment installed in the control room. Note 2 - EROS capability is unavailable due to BDBEE impact on communications infrastructure. Note 3 - Radiological release does not exist, offsite radiological assessment is not required . Note 4 - Initial NRC notification performed by SC. Continuous NRC Communications provided by Shift Communicator and other site-specific notifications assumed by EOF personnel once staffed and activated. N/R - Not Required N/A - Not Applicable Site Area Emergency declaration completion time General Emergency declaration completion time Estimated Task com letion and duration time
37